Draft

ADVISORY BOARD ON

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

REVIEW OF PETITION EVALUATION REPORT FOR

SEC-00224, ARGONNE NATIONAL LABORATORY-WEST 

REGARDING THE USE OF GENERAL AREA AIR SAMPLING 

FOR INTERNAL DOSE ASSESSMENT 

Contract No. 211-2014-58081 

SCA-TR-2016-SEC009, Revision 0 

Prepared by

Hans Behling, PhD, MPH 

Bob Barton, CHP

SC&A, Inc.

1608 Spring Hill Road, Suite 400 

Vienna, Virginia, 22182 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

July 2016 

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.
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SC&A, INC.: Technical Support for the Advisory Board on Radiation and Worker 

Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: 

Review of Petition Evaluation Report for SEC-00224, Argonne 

National Laboratory-West Regarding the Use of General Area Air 

Sampling for Internal Dose Assessment

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2016-SEC009 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: July 13, 2016

TASK MANAGER: John Stiver, MS, CHP [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file] 

DOCUMENT 

REVIEWER(S):

John Stiver, MS, CHP [signature on file]

Bob Barton, CHP [signature on file] 

Joe Fitzgerald [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 07/13/2016 Initial issue
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TABLE OF CONTENTS

Abbreviations and Acronyms ......................................................................................................... 4

1.0 Relevant Background Information ....................................................................................... 6

1.1 Fuel Cycle Facility Operations..................................................................................... 6

1.2 Radionuclides of Relevance to Internal Exposures at the FCF ..................................... 6

1.3 Monitoring for Internal Exposures................................................................................ 6

1.4 Overview of NIOSH’s Approach for the Reconstruction of Internal Doses at the FCF 

Post-1957 ...................................................................................................................... 8

1.5 Summary Conclusions .................................................................................................. 9

2.0 Review of FCF Air Sampling Data that May Be Used for Deriving Internal Dose .......... 10

3.0 Limitations Pertaining to Air Sampling Data for the Assignment of Internal Dose to FCF 

Workers ............................................................................................................................. 12

3.1 Long Air Sampling Times Employed at FCF............................................................. 12

3.2 Generic Limitations and Uncertainties Associated with General Area Air Sampling 

for Assessing Worker Intakes ..................................................................................... 13

3.3 Salient Data from the Caldwell et al. (1967) Study .................................................... 15

4.0 Summary Conclusions ....................................................................................................... 21

5.0 References .......................................................................................................................... 22

Attachment 1: General Area Air Sample Data for Room 25 (FCF) for the Month of September 

1963................................................................................................................................... 23

Attachment 2: Investigation and Characterization of Potential Periods of Shift Work at the Fuel 

Cycle Facility .................................................................................................................... 37
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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission

ANL-W Argonne National Laboratory-West

BZ breathing zone 

CAM continuous air monitor 

cfm cubic feet per minute 

CFR Code of Federal Regulations

Cs cesium

DAC derived air concentration 

DOL U.S. Department of Labor 

dpm/m3 disintegrations per minute per cubic meter

EBR-II Experimental Breeder Reactor-II

EE energy employee

FCF Fuel Cycle Facility

GA general area

HFEF Hot Fuel Examination Facility

H.P. Health Physics

IAEA International Atomic Energy Agency 

INEL Idaho National Engineering Laboratory 

μCi/cm3 microcurie per cubic centimeter

μCi/ml microcurie per milliliter

MAP mixed activation products 

MFP mixed fission products 

MPC maximum permissible concentration

Na sodium 

NIOSH National Institute for Occupational Safety and Health

NUMEC Nuclear Materials and Equipment Corporation 

Pu plutonium 

PuO2 plutonium oxide 

SEC Special Exposure Cohort 

Sr strontium 
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SRDB Site Research Database

TAN Test Area North

Th thorium 

ThO2 thorium oxide 

TREAT Transient Reactor Test Facility

TRU transuranic 

U uranium 

UO2 uranium oxide 

ZPPR zero power plutonium reactor 
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1.0 RELEVANT BACKGROUND INFORMATION

1.1 FUEL CYCLE FACILITY OPERATIONS

The Fuel Cycle Facility (FCF) performed radiological activities from July 1963 through 1979 

and beyond. The FCF was constructed as a pyrometallurgical reprocessing plant to meet the 

Experimental Breeder Reactor-II’s (EBR-II’s) nuclear fuel needs by reprocessing the breeder 

reactor’s fuels.

Steps to the pyrometallurgical reprocessing process took place in the FCF’s two hot cells (i.e., 

the Air Cell and Argon Cell). The Hot-Line included processes for disassembling, refining, 

refabricating, and reassembling EBR-II fuel subassemblies.

This irradiated fuel process was referred to at the FCF as Hot-Line fuel production. By 1969, the 

FCF had successfully completed its mission of demonstrating the processing and recycling of 

spent fuel to support EBR-II reactor operations. As a result, the FCF’s Hot-Line was phased out, 

and the Air and Argon Cells would only be used for shipping, inspecting, and testing irradiated 

reactor fuels. In support of EBR-II reactor operations, the FCF handled, packaged, and shipped 

spent fuels to the Idaho Chemical Processing Plant for reprocessing and packaged blanket and 

reflector subassemblies for disposal. The FCF also provided interim and post-irradiation 

handling, along with destructive and nondestructive examinations of fuel and material 

experiments. 

1.2 RADIONUCLIDES OF RELEVANCE TO INTERNAL EXPOSURES AT THE FCF

The following categories of radionuclides that may have contributed to internal exposures 

include the following: 

• Mixed fission and activation products 

• Plutonium (Pu-238, -239, -240, -241, -242) 

• Uranium (U-232, -233, -234, -235, -236, -238) 

• Thorium (Th-228, -230, -232) 

• Other actinides

• Other radionuclides (tritium, carbon-14, sodium-22 [Na-22], Na-24) 

Important to note and relevant to the interpretation of air sampling data discussed below is that 

while most dispersible sources of plutonium and thorium were present with mixed fission 

products (MFPs), freshly chemically separated Pu and Th would not have appreciable levels of 

MFPs. In contrast, the majority of dispersible forms of uranium was without MFPs. 

1.3 MONITORING FOR INTERNAL EXPOSURES

Section 5.1.6.3 of ORAUT-TKBS-0007-5, Revision 03, Idaho National Laboratory and Argonne 

National Laboratory – West – Occupational Internal Dose, provides a timeline of summary data 

pertaining to available internal monitoring, including the following statement:
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Routine bioassay of radiation workers has occurred since the beginning of site 

operations. However, formal documentation of the bioassay programs was not 

found for periods before 1981. [Emphasis added.]

The term “routine bioassay,” as used above, was limited in number and performed under 

restrictive conditions, as given by the following statement:

In general, workers were asked to submit to bioassay measurements whenever 

they were in an area where a CAM [continuous air monitor] alarm sounded. In 

addition, the fixed location and retrospective air-sampling system signaled the 

need for bioassay if elevated air sample results were detected. [Emphasis added.]

The role of air monitoring for the protection of workers from internal exposures was further 

explained in the following statements:

Section 5.1.6.2 of ORAUT-TKBS-0007-5 states:

The monitoring of radioactivity in the air in occupied areas was a basic element 

of the internal exposure prevention program. Beta/gamma-detecting CAMs were 

used from the beginning of all facility and program operations in routinely 

occupied areas....the primary contaminant radionuclides by activity were either 

MFPs or MAPs, which were beta/gamma emitters with maximum permissible 

concentrations/derived air concentrations (MPCs/DACs) above 1E-09 μCi/cm3

. 

TRU materials and uranium were available at some of the INEL facilities, but 

they were nearly always well-tagged with beta/gamma-emitting radioactivity that 

allowed beta/gamma-detecting CAMs to be used to warn of possible alpha

contamination or internal exposures. [Emphasis added.]

Section 6.3 of the SEC-00224 petition evaluation report (NIOSH 2016) states: 

...ANL-W used air sampling and radiological contamination monitoring 

programs as qualitative indicators of internal exposures, with routine bioassay

programs serving as verification programs that internal exposures had not 

occurred.

...The monitoring of radioactivity in the air in occupied areas was a fundamental 

component of the internal exposure control program. Beta/gamma CAMs were 

used from the beginning of all facility and program operations in routinelyoccupied areas. The CAM systems provided real-time air-activity evaluations 

while fixed air samplers provided retrospective data and an average air 

concentration in an area or building. 

...The conventional air-sampling units used were continuously-operating devices 

sampling at relatively low flow rates. Typical units sampled room air at 2 cfm on 

2-in.-diameter HV-70 or Millipore filters. Samples were removed daily, Monday 

through Friday, and counted for alpha and beta-gamma activities.

Section 7.2.2.2 of the SEC-00224 petition evaluation report (NIOSH 2016) states: 
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...In the instances where the air samples were counted for alpha radioactivity 

more than once due to the presence of short-lived alpha-emitting radionuclides, 

the latest result for gross alpha radioactivity will be used.... [Emphasis added.]

1.4 OVERVIEW OF NIOSH’S APPROACH FOR THE RECONSTRUCTION OF 

INTERNAL DOSES AT THE FCF POST-1957 

Fission and Activation Products. Based on Argonne National Laboratory-West’s (ANL-W’s) 

bioassay program after 1957, the National Institute for Occupational Safety and Health (NIOSH) 

believes that it has sufficient in-vitro and in-vivo bioassay data to allow for sufficiently accurate 

estimation of internal doses attributable to mixed fission and activation products for EBR-II/FCF 

Complex workers during the entire period that radiological operations took place. 

Actinides with Mixed Fission Products. For the majority of instances where MFPs accompanied 

actinides, intake levels of actinides will be estimated by multiplying the bioassay assessed 

strontium-90 (Sr-90) and/or cesium-137 (Cs-137) intakes by actinide-to-Sr-90 and/or actinide-toCs-137 ratios. 

Uranium, Thorium, and Plutonium without Fission Products. Due to the availability of extensive 

air sampling data, NIOSH believes that air sampling data are sufficient for bounding internal 

radiation doses to uranium, thorium, and plutonium by means of the following criteria: 

• Uranium. For some EBR-II facilities and exposure to uranium without MFPs, intakes will 

be bounded by using 10% maximum permissible concentration (MPCair) values from 

available air monitoring data.

At the FCF, estimates of internal dose to uranium (without MFPs) for the time period 

between August 1967 and June 1983 will be based on inhalation intakes using gross 

alpha radioactivity of air samples. (Note: After July 1983, bioassay, when available, may 

be used instead of air monitoring data.) 

• Thorium. During the period of 1963–1967, dispersible thorium without MFPs may have 

exposed workers at the FCF in Room 205 due to the use of thoria (thorium dioxide 

[ThO2]) to coat crucibles and molds for the FCF’s hot line. For this period, NIOSH 

intends to bound potential intakes of thorium by assuming intakes at 10% of the MPCair

that ANL-W was using. 

• Plutonium. The plutonium-bearing Mark-II loops that were handled at the FCF mostly 

contained enriched uranium oxide (UO2) with lower quantities of plutonium oxide 

(PuO2). But due to the much shorter half-life of plutonium (and, therefore, the higher 

specific activity of plutonium), NIOSH will conservatively assume that 100% of gross 

alpha activity represents plutonium. Using available records that identify each period 

when plutonium-bearing loop experiment test sections were handled in FCF Rooms 22 

and 27, acute intakes for plutonium will be estimated from corresponding available air 

sample data. For chronic plutonium intakes, NIOSH simply states that “...chronic intakes 

will be assessed as a bounding approach with specifying a method such as a fraction of 

the MPCair value for Pu.” 
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1.5 SUMMARY CONCLUSIONS

Based on statements presented above, internal dose assessment for FCF workers post-1957 will 

be derived using the following data:

1. For fission and activation products, internal dose is based on in-vitro and in-vivo 

bioassay data. 

2. For all actinides (that include uranium, thorium, and plutonium) associated with MFPs, 

internal doses are derived by multiplying the bioassay-derived intakes of Sr-90 and/or 

Cs-137 with actinide-to-Sr-90 and/or actinide-to-Cs-137 ratios. Thus, internal doses for 

actinides are derived indirectly from bioassay data that reflect in-vitro urinalysis data 

and/or in-vivo whole body counting. 

3. For uranium and thorium without MFPs, bounding estimates of internal exposures are 

based on 10% of the MPCair values that ANL-W used.

4. For plutonium without MFPs, acute internal doses are based on available air sample data. 

For chronic exposures, intakes will be assessed using a bounding approach. 

Relevant to this report is NIOSH’s proposed use of air monitoring data for the assignment 

of internal dose to FCF workers exposed to uranium, thorium, and plutonium without the 

presence of MFPs. 
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2.0 REVIEW OF FCF AIR SAMPLING DATA THAT MAY BE USED

FOR DERIVING INTERNAL DOSE

Air sampling data for Room 25. During the period of the FCF Hotline fuel production between 

August 1963 and November 1967, ThO2 was used to coat crucibles and mods in Room 25 as a 

refractory coating. NIOSH’s SEC-00224 petition evaluation report provides the following 

example of air sampling data that may be used for assigning a bounding value for Th intake 

(NIOSH 2016): 

Figure 7-2 provides an example of a 1963 air sample result for FCF Room 25. 

During the collection period for this sample, some thoria was spilled on the floor 

from one of the hoods in Room 25 (FCF Survey Reports, 1963). 

Figure 1 shows the air sampling data referenced in the preceding quotation as Figure 7-2. 

Inspection of Figure 1 identifies the following information/sampling parameters:

• The “routine” air sampling started at 2:20 p.m. on September 17, 1963, and terminated at 

11:38 a.m. on September 18, 1963, for a total air sampling time of 1,289 minutes (21.5 

hours).

• With an air flowrate of 1 ft3/minute, the total air volume sampled was 39 m3, which 

corresponds to an air flow rate of 1.81 m3

/hr.

• The air sample was counted for alpha activity following three decay times of 15 minutes, 

240 minutes, and 1,512 minutes. 

• With the decay of short-lived alphas, a final decay time of 1,512 minutes (or 25.2 hours), 

the residual alpha of thorium activity on the filter media corresponded to 4 disintegrations 

per minute per cubic meter (dpm/m3) or 3% of the MPCair for a 40-hour per week 

exposure (MPC(40)). (Note: MPCair for thorium natural is given in Appendix B of 10 

CFR 20 as 6×10-11 microcurie per milliliter, which converts to 133.2 dpm/m3

.) 

Figure 7-2 of the SEC-00224 petition evaluation report, as shown in Figure 1, is 1 of 11 

“routine” air samples taken for the month of September 1963 along with 3 “special” air samples, 

which reflect the assessment of a ThO2 floor spill on September 18, 1963. Air sampling data 

sheets for the 11 routine and 3 special air samples are enclosed in this report as Attachment 1 and 

cited in chronological order. 
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Figure 1. Figure 7-2 from NIOSH’s SEC-00224 Petition Evaluation Report 

Source: FCF Survey Reports 1963, Figure 7-2: Example FCF Room 25 Air Sample Result from 

1963.
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3.0 LIMITATIONS PERTAINING TO AIR SAMPLING DATA FOR THE 

ASSIGNMENT OF INTERNAL DOSE TO FCF WORKERS 

In addition to the sampling data sets enclosed as Attachment 1, SC&A reviewed several other 

representative data sets and concludes the following: 

• For uranium, thorium, and plutonium without MFPs, air sampling data reviewed by 

SC&A support NIOSH’s claim that the recorded air concentrations typically were below

10% of the MPCair (40) value. On the assumption that measured general area (GA) air 

sampling data accurately represent levels of contamination breathed by workers, 

NIOSH’s proposal to assign 10% of the MPCair (40) as a bounding intake value would 

appear appropriate/claimant favorable for the unmonitored workers. 

• The assumption that measured air concentrations obtained from GA air sampling are truly 

representative of air concentrations respired by workers during facility operations, 

however, has to be questioned at two levels, as explained in Sections 3.1 and 3.2 below. 

3.1 LONG AIR SAMPLING TIMES EMPLOYED AT FCF

For routine GA air sampling at the FCF, the low flowrate of 1 ft3/minute corresponds to 1.695 

m3

/hr, which is only marginally greater than the respiration rate of 1.2 m3/hr assumed for a 

worker. In order to sample a sufficiently large volume of air, sampling times for the 11 routine 

air samples (see Attachment 1) ranged from a low of 1,289 minutes (or 21.5 hours) up to 5,690 

minutes (or 94.8 hours), with a mean duration of 2,443 minutes (or 40.7 hours). A check of the 

dates on which these air samples were taken reveals that three were initiated on a Friday and 

terminated on the next workday. The longest sample time of 5,690 minutes (or 94.8 hours) 

represents a 4-day time period that corresponds to the entire Labor Day weekend of 1963 (see air 

sample #1 of Attachment 1). SC&A’s investigation into the typical duration of daily radiological 

activities at FCF indicates a mix of “typical single-shift” operations (assumed to be 0800–1700 

hours), as well as indications of “swing-shift” or “double-shift” operations, which would be 

outside of the typical work hours. Additionally, it appears that “off-normal” operations, such as 

unique maintenance, installation, or removal operations, may have occurred sporadically at the 

facility during the period of interest (1963–1969).1

1 The period of 1963–1969 represents the time frame for which the FCF was conducting activities related to 

disassembling, refining, refabricating, and reassembling EBR-II fuel subassemblies. After this time, the main 

activities at FCF involved inspecting, testing, and shipping irradiated reactor fuels to the Chemical Processing Plant 

for reprocessing and refining.

 However, SC&A did not observe a clear 

temporal pattern to discern when site practices may have transitioned from a typical work shift to 

activities that required expanded radiological work hours. The reader is referred to Attachment 2 

for a description of available information used by SC&A to characterize typical operational work 

duration at FCF. 

Given the relatively long sampling times of the fixed air samplers, which necessarily measured 

both operational and non-operational air concentrations at FCF, recorded GA air concentrations 

 
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should not be considered representative of air concentrations encountered by workers during 

typical facility operations. 

3.2 GENERIC LIMITATIONS AND UNCERTAINTIES ASSOCIATED WITH 

GENERAL AREA AIR SAMPLING FOR ASSESSING WORKER INTAKES 

As acknowledged in Section 5.1.6.2 of ORAUT-TKBS-00070-5, GA air sampling was intended

neither to serve the purpose of assessing internal exposures nor to replace the need for bioassay 

monitoring, as given in the following statements: 

The monitoring of radioactivity in the air in occupied areas was a basic element 

of the internal exposure prevention program....

In general, workers were asked to submit to bioassay measurements whenever 

they were in an area where a CAM alarm sounded. In addition, the fixed location

and retrospective air-sampling system signaled the need for bioassay if elevated

air sample results were detected. [Emphasis added.]

While air sampling is an important component in radiological protection, it is equally important 

to understand the limitations of air monitoring data and their interpretation. There are two major 

categories of air sampling that are represented by (1) fixed or GA air sampling and (2) lapel air 

samplers, commonly called personal breathing zone (BZ) air samplers. In contrast to the fixedlocation GA samplers, BZ air samplers are worn with a filter located on the lapel, where air is 

sampled that closely corresponds to the air respired by the worker. 

Under conditions where a radioactive contaminant has been uniformly dispersed, data obtained 

from a GA and a BZ air sample can be expected to show similar values. In reality, however, 

release of dispersible contaminants and their distribution in air results in concentration gradients 

that vary over space and time. Not surprisingly, a number of studies have consistently shown that 

GA air samples poorly correlate with BZ lapel air samples (Brunskill and Holt 1967; Caldwell et 

al. 1967). 

Salient Data from the Brunskill and Holt 1967 Study. Aerosol studies of plutonium and uranium 

plants at the Windscale and Springfields Works of the United Kingdom Atomic Energy 

Authority were conducted to compare the data from static and personal air samplers in a number 

of plant and laboratory areas in order to formulate a general policy for air sampling. 

From study data, it was concluded that for any specific area of investigation, the integrated 

“exposure” shown by a personal air sampler is almost invariably greater than the integrated 

“exposure” shown by static samplers over the same period. The ratio of “exposures” varies with 

the operation being carried out and varies between wide limits for operators carrying out nearly 

similar duties.

In uranium-active areas, the ratios (i.e., BZ/GA) varied by as much as 80-fold during a particular 

shift cycle, with significant variations of BZ “exposures” among individuals in a given shift. 

In plutonium-active areas, the ratio of exposures varied between even wider limits over 

comparable periods of investigation. Figure 2 shows the variations in the ratios of personal BZ 
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air exposures to fixed GA air sampler exposures, with activity shown by the BZ air samplers in 

units of dpm/m3 xx Hours. Figure 2 shows the following relationship between BZ and GA sample 

values:

• Nearly all GA air samples are within a factor of 100 of the lapel BZ air samples, while 

most are within a factor of 10. 

• Secondly, Figure 2 shows that for increasing BZ air concentrations, there is decreasing 

correlation with the GA air sample.

On the basis of these data, the authors concluded that (1) for any specific area monitored, the 

integrated exposures shown by personal BZ air samplers are consistently greater than the 

integrated exposure shown by a fixed GA air sampler over the same time period, and 

(2) results from all uranium and plutonium areas investigated show that the fixed GA air 

samplers are incapable of indicating the true conditions in the BZ of the operators. However, 

the option exists that by applying a multiplying factor to the GA air sampling result, a 

reasonable prediction of the BZ air concentration may be estimated. A reasonable 

multiplying factor of 10 should be considered for converting GA air sample values to BZ air 

concentrations. 
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Figure 2. The Variation in the Ratio of Personal to Static Daily Air Exposures with Activity 

Shown by the Personal Sampler

Source: Brunskill and Holt 1967.

3.3 SALIENT DATA FROM THE CALDWELL ET AL. (1967) STUDY 

Nuclear Materials and Equipment Corporation (NUMEC) is a nuclear fuel facility where 

uranium and plutonium workers were monitored by lapel BZ air samplers, as well as by fixed 

GA air samplers.

Fixed-station air sampler data that span a 2-year period were compared with 594 BZ samples at 

the plutonium laboratory and 459 BZ samples at the uranium plant. The BZ samplers were for 

single shifts of an 8-hour day. These data were matched for time and location to fixed station air 

sample data for comparison. Results of this comparison are summarized below. 

Figure 3 reveals the following relationships for the distribution of BZ samples and corresponding 

GA air samples for plutonium and uranium: 

Pu Laboratory Data

• Generally “good” agreement (+100% to -50%) between plutonium BZ and GA air 

samples corresponded to 27% of plutonium BZ samples. 
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• Almost 9% of the plutonium BZ samples were less than 50% lower than the GAs. 

• 64% of plutonium BZs exceeded the GA concentration by a factor of 2 or more. 

• 23% of plutonium BZs exceeded the GA concentration by more than a factor of 10. 

• The single highest plutonium BZ sample-to-GA ratio observed was 9,870. 

Uranium Plant Data

• Generally good agreement (+100% to -50%) between uranium BZ samples and GA air 

samples corresponded to about 19%. 

• 35% of uranium BZs exceeded fixed GA concentrations by a factor of 10 or more.

Important to note is the fact that, while the median BZ/GA ratios for both the plutonium and 

uranium facilities were below 10, the very skewed distribution for higher air concentrations 

makes high-level exposures important when computing the average exposures that may be based 

on fixed GA sample data, as shown in Figure 3. 

The importance of personal BZ samples under conditions of higher air concentration is more 

clearly demonstrated in Figure 4. BZ/GA ratios for all plutonium exposures exceeding 10 MPCs 

for an 8-hour shift are plotted against the BZ concentration. Inspection of Figure 4 demonstrates 

three features that define the relationship between BZ and GA data.

The first is the high variability of the BZ/GA ratio for any given BZ air concentration. For 

example, for BZ values between 40 to 50 dpm/m3, the fixed-area air sample concentration varied 

from one-half to one-eight hundredth of the BZ concentration. Given the high degree of 

variability, the authors of this study questioned the ability to select a meaningful factor (such as 

the factor of 10 proposed by Brunskill and Holt [1967]) by which the GA concentration is 

multiplied by 10 to estimate the actual exposure(s) to individual workers. 

Secondly, as BZ air concentrations increase, there is an upward trend (i.e., increase) in the 

BZ/GA ratios. For example, for BZs between 400 to 480 dpm/m3

, the fixed-station air 

concentrations varied from about one-hundredth to about one-three hundredth of the BZ 

concentration. 

Thirdly, the solid line in Figure 4 represents the line where the fixed GA air samplers would 

indicate the soluble MPCair (given as “MPCa” in the figure) value for plutonium. For all the data 

above the line, the GA value was less than MPCa. Only those below the line indicated that a

hazardous air concentration existed.

Similar discrepancies between BZ and GA air samples were documented for the uranium facility 

at NUMEC (Table 1). For the 459 BZ air samples that were matched against GA values, 333 

indicated air concentrations above MPC values, while GA samples suggested air concentrations 

below MPC values. This implies that for almost 73% of the time the GA sampling network failed 

to warn personnel when greater than permissible exposure conditions existed. 
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Caldwell et al. (1967) concluded with the following warning: 

This is an important point. Many radioaerosol exposures are going unnoticed 

because the nuclear industry is depending on fixed station air sampling. 

...The failure of fixed station samplers could not be more graphic. 
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Figure 3. Ratio of Lapel Sampler Concentration to Fixed Station Sampler Concentration, NUMEC Nuclear Facilities 1966–

1967 

Source: Caldwell et al. 1967.
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Figure 4. Breathing Zone Concentration, NUMEC Plutonium Laboratory 1966–1967 

Source: Caldwell et al. 1967.
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Table 1. Hazard Indicability, Lapel Samples (BZ) vs. Fixed Station Samples (GA), NUMEC 

Uranium Plant, 1966–1967

Condition Indicated Number Recorded Frequency

BZ>MPC

GA<MPC 300 .654

BZ>10 MPC

GA<MPC 33 .072

BZ<MPC

GA<MPC 54 .118

BZ<MPC

GA>MPC 2 .004

BZ>MPC

GA>MPC 70 .152

Total BZ Samples = 459

Total GA>MPC = 72

Tota403l BZ>MPC = 403

Source: Reproduced from Caldwell et al. 1967.
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4.0 SUMMARY CONCLUSIONS

In the absence of sufficient bioassay data for deriving internal exposures for years 1958 and 

after, NIOSH proposes the use of GA sampling data. Specifically, GA air sampling data will be 

used for bounding inhalation intakes of uranium, thorium, and plutonium that may have existed 

in the absence of MFPs. 

On the basis of recorded/available GA air sample data, NIOSH concluded that an air 

concentration of 10% MPCair defined for a 40-hour work week provides a bounding value for 

potential intakes of uranium, thorium, and plutonium at the FCF (and other work locations at 

ANL-W).

SC&A’s review of GA air sampling data confirms that the recorded air concentrations most often 

were below the 10% level of MPC(40) as shown in Attachment 1. In principle, the recorded data 

would support NIOSH’s selection of this value as a “bounding” estimate for assigning internal 

doses. 

Support and commitment for the use of the 10% MPC value, however, would have to rely on the 

unconfirmed assumption that GA air concentrations closely correspond to operational air 

concentrations to which workers were exposed. 

SC&A’s review of FCF air data, typical daily operations, and assessment of NIOSH’s proposed 

use of GA air sampling data identified two issues of concern. The first concern centers around 

the use of GA air samplers with a low airflow. Low airflow rates required sampling times of up 

to 4 days, which necessarily correspond to periods when no work was performed (and no 

workers were present). Thus, it is reasonable to conclude that air concentrations during nonworking hours differed significantly from air concentrations that would have exposed workers 

during normal facility operations that were likely limited to an 8-hour shift Monday through 

Friday during many periods. 

A second and more serious concern regarding the use of GA air sampling data is the generic lack 

of parity between air concentrations measured by GA air samplers and lapel air samplers worn 

by the individual workers. Study data, including those of two nuclear fuel processing facilities 

cited in this review, have consistently demonstrated the poor correlation between GA and BZ air 

sample data with BZ/GA ratios that spanned several orders of magnitude. 

Given the high degree of uncertainty surrounding GA sampling data at the FCF (and possibly 

other locations at ANL-W), SC&A concludes that NIOSH’s proposed value of 10% MPC(40) as 

a bounding value for internal dose assessment lacks credibility. 
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5.0 REFERENCES

Brunskill and Holt 1967. R.T. Brunskill and F.B. Holt, “Aerosol Studies in Plutonium and 

Uranium Plants at the Windscale and Springfields Works of United Kingdom Atomic Energy 

Authority,” Proceedings of a Symposium on Instruments and Techniques for the Assessment of 

Airborne Radioactivity in Nuclear Operations, International Atomic Energy Agency, Vienna, 3–

7 July 1967, IAEA Report No. SM-95/30, pp. 463–475. Available at 

http://www.iaea.org/inis/collection/NCLCollectionStore/_Public/44/072/44072788.pdf?r=1 

Caldwell et al. 1967. R. Caldwell, T. Potter, and E. Schnell, “Bioassay Correlation with 

Breathing Zone Sampling,” Health and Safety Department, Nuclear Materials and Equipment 

Corporation, prepared for presentation at the 13th Annual AEC Bioassay and Analytical 

Chemistry Conference. 1967. [SRDB Ref. ID 29599]

FCF Survey Reports 1963. Radiation Survey Reports, Air Sample Data, Smear Data Sheet, 

Counter Data: Background and Yield Calculations FCF September 1963, Argonne National 

Laboratory. September 1963. [SRDB Ref. ID 146515]

NIOSH 2016. SEC Petition Evaluation Report: Petition SEC-00224, National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. February 18, 2016. 

ORAUT-TKBS-0007-5. 2010. Idaho National Laboratory and Argonne National Laboratory – 

West – Occupational Internal Dose, Revision 03, Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. March 2, 2010. 
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third party without the written consent of the individual to whom the information pertains is strictly prohibited.

ATTACHMENT 1: GENERAL AREA AIR SAMPLE DATA FOR ROOM 25 (FCF) 

FOR THE MONTH OF SEPTEMBER 1963

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ATTACHMENT 2: INVESTIGATION AND CHARACTERIZATION OF 

POTENTIAL PERIODS OF SHIFT WORK AT THE FUEL CYCLE

FACILITY

As described in the main body of this report, reconstruction of chronic intakes to alpha-emitting 

contaminants that are independent from associated fission products are dependent on fixed air 

samples, which operated at relatively low flow rates that are averaged over a day or more. It is 

currently assumed that certain areas of the Experimental Breeder Reactor-II (EBR-II) complex 

(such as the main reactor areas) operated on essentially a 24-hour schedule. However, the Fuel 

Cycle Facility (FCF) appears to have operated on a regular work schedule during certain periods 

(8 hours per day, 5 days per week) and a two-shift schedule that would expand radiological work 

hours during other periods. 

Consultation with NIOSH during a programmatic internal technical call (held on June 15, 2016) 

confirmed that the FCF was not operated on a continuous 24-hour-per-day schedule. Increases in 

the operation of the facility beyond a typical 40-hour work week were most likely dependent on 

the production requirements of the EBR-II complex at the time, as well as any off-normal 

maintenance activities required at FCF. As noted in Section 3.1 of this report, continuous fixed 

air samples averaged over a 24-hour period (or more) may underestimate the intake potential for 

workers during the actual operational activities at FCF. This would be particularly important for 

periods when the FCF operated on a single-shift schedule, as well as periods for which air 

samples were taken over the course of a weekend and/or holiday in which no radiological work 

was likely to take place. 

In order to attempt to characterize the practice of multiple shifts and/or radiological work 

occurring outside of typical working hours at FCF, SC&A examined available interviews with 

former FCF workers, as well as a focused review of health physics coverage activities that

occurred during the principal period of interest from 1963 to 1969.1

1 The period of 1963–1969 represents the time frame for which the FCF was conducting activities related to 

disassembling, refining, refabricating, and reassembling EBR-II fuel subassemblies. After this time, the main 

activities at FCF involved inspecting, testing, and shipping irradiated reactor fuels to the Chemical Processing Plant 

for reprocessing and refining. 

 These activities include, but 

are not limited to, external radiation surveys, routine area contamination swipes, and Health 

Physics (H.P.) oversight of individual operations. The former mode of investigation (review of 

worker interviews) provides firsthand knowledge of typical work practices at FCF; however, 

often this information is more anecdotal than quantitative, and the number of relevant 

interviewees is limited. The latter mode of investigation (H.P. activities) provides a more 

quantitative characterization, though this method is not without unavoidable uncertainties that 

are described later in this section. 

SC&A’s examination of available worker interviews available in the Site Research Database 

(SRDB) identified only five interviews that provided relevant information germane to the 

potential for shift work at FCF. The relevant information is summarized in Table 2-1. Two of the 

five interviewees worked at FCF, but outside the main period of interest. One worker 

interviewed indicated shift work took place and that, in some cases, “coverage around the clock”

took place. However, this worker was mainly located at the EBR-II reactor building and may not 

 
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have been referring directly to FCF. Still another interviewee indicated around-the-clock shifts 

(i.e., triple shifts). However, this was specific to a construction project that only lasted three 

weeks. The most pertinent interview (SRDB Ref. ID 147446) worked at FCF during the period 

of interest and also provided general dates as to when the facility added a continuous second shift 

(described as the late 1960s). 

Table 2-1. Summary of Information Relevant to the Potential for Shift Work at FCF from 

Former Worker Interviews Available in the SRDB

SRDB 

Reference 

for 

Interview

Relevant Information from Worker Statements

142386 

– Energy employee (EE) is a claimant with U.S. Department of Labor (DOL) Covered 

employment at Argonne National Laboratory-West (ANL-W) from , 1967, 

to , 1995. 

– Worked primarily at EBR-II main building, also worked at L&O (chemistry labs), 

Transient Reactor Test Facility (TREAT), Zero Power Plutonium Reactor (ZPPR), 

research labs. Promoted to a Radiation Safety Tech RadTechs at 

Hot Fuel Examination Facility (HFEF), FCF, and L&O. 

– The interviewee notes that sometimes he worked 12-hour shifts with “coverage around 

the clock,” also notes sometimes shift work took place. 

– There was no direct connection between overtime/shift work and FCF specifically. For 

example, those statements could represent work in the main EBR-II building. 

147010 

– Statement from interviewee: “EBR-II was a 24 hour operations [sic] but FCF was 

typically just a day operation.” 

– EE is not a claimant, and employment at ANL-W did not begin until February 1977. 

147011 – Statement from interview: “FCF was a day operation.” 

– EE is not a claimant but appears to only have worked at FCF beginning in 2000. 

147022 

– EE was a pipefitter who started work at FCF in 1963. 

– Interviewee describes shift work on a specific construction project: three shifts, eight

men per shift, 3 weeks in duration. 

– EE worked for Atlas Mechanical, which was a subcontractor at the ANL-W site.

Typically, construction work in or near radiological areas was performed by the prime 

contractor. 

147446 

– Statement from interview: “In September 1964 (or 1965) [the EE] transferred to the 

Fuel Fabrication Facility as a technician. Originally FCF operated only one shift, but 

by the late 1960’s a second shift was added and continued until HFEF-North came 

online.”*† [Emphasis added.] 

– EE is a claimant; however, additional information was not identified in the available 

claim files other than that the EE indicated they worked overtime (i.e., 40+ hours per 

week).

*SC&A assumes that the claimant’s reference to the “Fuel Fabrication Facility” is actually representative of the Fuel 

Cycle Facility.

†Note: Construction of HFEF-North appears to have been completed sometime during 1972.

The second facet of SC&A’s analysis involved the examination of available H.P documentation, 

including routine area surveys and contamination measurements. The documentation of such 

activities typically contains a start and end time for a given activity. The general concept behind 

this study is that H.P. monitoring activities, which take place after the standard “single-shift” 
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work (assumed to be 0800 to 1700, or 8:00 am to 5:00 pm), could be potentially indicative of 

shift work occurring on that day. 

As mentioned previously, this type of investigation carries considerable uncertainty when 

drawing firm conclusions as to when regular shift work may have been implemented versus nonroutine maintenance activities. For example, some activities occurring outside of standard 

working hours may have taken place as a matter of necessity or convenience. Examples of which 

may include:

• Surveys of areas of FCF that may pose a considerable difficulty during normal working 

hours due to the particular operations occurring in those areas 

• Special or “off-normal” maintenance, decontamination, or installation activities that may 

interrupt normal radiological operations 

Additionally, survey reports currently available in the SRDB appear to be incomplete for the 

period of interest. SC&A assumes that the unavailable records are the result of data capture 

efforts aimed at obtaining a representative sample of area monitoring records rather than a 

complete dataset. The practice of capturing a representative and/or example set of records has 

been utilized during similar data capture efforts at other sites. 

The percentage of total days in a given month for which H.P. monitoring data were captured is 

shown in Figure 2-1. As seen in the figure, the number of days in a given month for which H.P. 

area survey measurements are available for FCF varied significantly across the period of interest.

Notably, no area survey data were found for the following time periods: July 1963, August–

November 1965, and September 1967. The time period that generally displayed the highest 

number of days with available H.P. area monitoring was January through May 1967 (~84% of 

the days in the month). 
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Figure 2-1. Percentage of Days per Month for which Health Physics Area Monitoring Data 

Are Available in the SRDB

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

Percentage of Days in Month with Available H.P. Coverage

Time Period (Month - Year)

Despite these noted uncertainties, examination of available H.P. area monitoring records 

provides important insight and perspective as to the operational work history at FCF, particularly 

in a temporal context. In order to quantify the potential for shift work, SC&A compared the 

number of days per month for which H.P. area monitoring is available versus the number of 

those days for which there were demonstrated H.P. activities after a typical single-shift working 

hours (assumed to be 0800 to 1700 hours). The percentage of such “monitored” days per month 

exhibiting characteristic is shown in Figure 2-2. As seen in the figure, the percentage of days in 

which H.P. activities occurred after 1700 hours varied significantly by month. In general, it 

appears that the occurrence of off-normal activities was relatively low from March 1963 through 

May 1965, when the percentage ranged from 0 to 20%. 

After this timeframe, the observed number of days with “off-normal” H.P. activities generally 

increased but also varied significantly from month to month. If one accepts that the available 

H.P. survey reports are a representative sample, then this would indicate that the implementation 

of a second shift, or “swing shift,” may not have occurred as part of general change in policy at 

FCF but rather was implemented on an “as needed” basis. 
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Figure 2-2. Percentage of Monitored Days Exhibiting Health Physics Coverage after 1700 

Hours (5 p.m.) per Month for the Fuel Cycle Facility

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

Percentage of Monitored Days Exhibiting 

Health Physics Activities after 1700 Hours

Time Period (Month - Year)

The preceding analysis focused on the observed H.P. survey activities occurring after 1700 

hours; however, it is also possible activities occurred prior to the start of a typical single-shift 

workday (i.e., prior to 0800 hours). Such activities might be indicative of an additional third shift 

being utilized at FCF. While there were observed H.P. activities identified prior to 0800 hours on 

a given workday, they were exceedingly rare. Nearly 88% of months reviewed in this analysis 

showed no H.P. activity prior to 0800 hours. The highest incidence of work occurring prior to 

0800 hours occurred in January and February of 1967 (4 of 22 and 6 of 23 days per month, 

respectively). Examples from this time frame are shown in Table 2-2. 

As seen in Table 2-2, the descriptions of H.P. activities occurring prior to 0800 hours during the 

January–February 1967 time frame appear to be associated with off-normal maintenance and 

removal of radioactive components for shipment to other areas. SC&A did not find any evidence 

of a third shift being utilized at FCF, which is consistent with NIOSH’s understanding per the 

technical conference call on June 15, 2016. 
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Table 2-2. Examples of H.P. Surveys Performed in January and February 1967 prior to 

0800 Hours

Date Start 

Time

Description

Thursday, January 12, 1967 0010 Survey of single individual following an attempted 

decontamination operation. The last H.P. operation on the 

previous day occurred at 2330 hours involving a maintenance 

operation to replace cell plugs for the air cell which took 

place on the roof. 

Friday, January 13, 1967 0320 Personnel surveys following decontamination activities on 

FCF roof. 

Monday, January 16, 1967 0430 H.P. coverage on entry to the “Wind and Weather” shelter on 

the roof and maintenance on a manipulator device.

Friday, January 20, 1967 0030 Continued H.P. coverage on manipulators from the “Wind 

and Weather” area of the FCF roof (lasted about 4 hours). 

Wednesday, February 01, 

1967

0100 H.P. coverage of repair work on the cranes within the air cell, 

special H.P. procedures provided for the work. 

Thursday, February 02, 1967 0530 H.P. coverage for the loading of a “glass scrap coffin.”

Sunday, February 12, 1967 0330 H.P. coverage during the transfer of vycor molds into the air 

cell with floor plug removed.

Thursday, February 16, 1967 0700 Survey loading of three rods into EBR-I coffin for shipment 

to Test Area North (TAN), special H.P. procedures provided 

for the work.

Saturday, February 18, 1967 0600 Monitoring the transfer of a subassembly from cell to “old” 

EBR-I coffin. 

Notes: “All ASSE to go to Burriel ground [sic]”

Wednesday, February 22, 

1967

0005 Survey at air cell transfer port, for transfer out of 24 slave 

hands.

In addition to analyzing H.P. activities occurring outside of the typical hours for a single shift 

operation, SC&A analyzed the number of instances per month for which H.P. activities occurred 

on Saturday and Sunday. This is particularly important for instances where the fixed air samples 

may have been set on Friday morning and run continuously until being collected and analyzed on 

Monday morning. The number of Sundays and Saturdays per month for which H.P. monitoring 

activities occurred is shown in Figure 2-3. 

As the figure shows, the instances of H.P.-related work occurring on Saturday was either zero or 

one for the majority of months. The highest observed occurrence of Saturday H.P. coverage 

occurred from roughly January 1967 to May 1967 (two to four Saturdays per month). Notably, 

this uptick in activities also corresponded to the time frame in which SC&A observed the most 

days per month with available H.P. survey data (see Figure 2-3), as well as a relatively high 

incidence of H.P. activity after 1700 hours (see Figure 2-2). The occurrence of H.P.-related work 

on Sundays was a much rarer occurrence, with over 91% of the available monthly data indicating 

no work on Sunday at all. Only a single month (May 1967) contained H.P. survey data for more 

than one Sunday. Aside from the period from January to May 1967, there does not appear to be a 

clear temporal trend in potential work occurring on weekends. 
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Figure 2-3. Number of Weekend Days per Month with Health Physics Activities

0

4

1

2

3

# of Sundays

Time Period (Month - Year)

Number of Weekend Days with Health 

Physics Coverage per Month

# of Saturdays

In summary, SC&A identified several pieces of evidence that shift work (or in some cases offnormal work) occurred at FCF throughout the period of interest. However, SC&A did not find 

evidence that a uniform temporal shift in plant operations occurred that may have necessitated 

regular “swing shift” or “off-normal” H.P. activities. The exception to this is the first half of 

1967, when there was a relative increase in H.P.-related activities occurring both before and after 

the typical single-shift hours. In addition, there was a general increase in H.P. activities occurring 

on weekends during this time.